Tax, International

Latin America

• Advise U.S. and international investment funds regarding tax preferred structures for joint U.S.-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits.
• Advise foreign financial institutions (non-U.S.), foreign entities and their advisors and employees regarding the application, strategic decisions and implementation of the federal tax law, Foreign Account Tax Compliance Act.
• Represent international entertainers, many located in the Latin American region — including various Grammy Award winners — regarding tax planning considerations of their worldwide publishing, promotion, concerts, tax-exempt foundations, sales, and related activities.
• Assist numerous U.S. developers (joint ventures, land and construction development) with Mexican and Latin American (e.g., Costa Rica and Guatemala) real estate acquisitions and development; structuring global operations, financing, equity investment, repatriation of funds and tax treaty benefits.
• Represent various Mexican and Latin American, manufacturing, technology and agricultural companies with U.S. and worldwide joint venture, distribution and sales companies.
• Assist multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with U.S. and Latin American individual and institutional investors.
• Assist various multi-million dollar Mexican real estate land owners with U.S. joint venture real estate developments.

Asia

• Negotiated a platform joint venture agreement with Morgan Stanley Real Estate Investment Funds on behalf of co-investor/managers for management, development, and investment in retail property located in the People’s Republic of China and India (venture size of $300 million).
• Counsel clients in international project financing and access to capital market in Hong Kong, Taiwan and Mainland China.
• Counsel clients in partnering negotiations, technology acquisition, licensing, joint research, development and outsourcing production and distribution relationships for clients in the U.S., China, and other countries.
• Counsel clients in the greater Pacific Rim region in investments and doing business in the U.S.
• Enforce actions on behalf of U.S. and international clients against IPR abuses in China.
• Prosecute administrative and criminal enforcement actions against counterfeiters resulting in seizure of substantial quantities of counterfeits and criminal convictions of Chinese counterfeits. In one action, case was cited by the China Quality Brand Protection Committee as one of the top ten model cases of IPR enforcement in China for 2013-2014.
• Enforce actions against IPR abuses on top Chinese Internet trade portals on behalf of clients with innovative, proprietary technology resulting in the removal of counterfeit products valued at over $12 million; success rate over 98% over an 18-month period.
• Assist clients in the execution of their Global IPR enforcement strategy (administrative and judicial enforcement and raids and customs seizures against counterfeiters and infringers).

Procopio International Tax Institute (PITI)

Having celebrated its 20th anniversary in 2025, the PITI Conference marked two decades of excellence as the go-to forum for internationally recognized leaders in the field of international taxation. Over the years, this event has provided an unparalleled platform for education, collaboration, and networking. Stay tuned for information on 2026.